Subject: File No. S7-28-04
From: David K. Vun Kannon

To be effectively used in an electronic environment, the comment letters need to be released with metadata that will allow search and query by databases and web search engines.

I suggest that the SEC adopt an XML format of the Dublin Core metadata standard. Guidance on this subject is available at:
http://dublincore.org/documents/dc-xml-guidelines/

The published metadata should include the CIK and other filing identifier that will allow the comment to be tied back to the original filing.

My suggestion does not include the idea that the text of the comment letter should be released as anything other than plain text. Indeed, plain text would be preferrable to a proprietary format such as Microsoft Word or Adobe PDF. If the text of the comment letter was released as HTML, that would be acceptable, and would allow the metadata to be placed in the HEAD of the document.

David vun Kannon is a senior manager in KPMGs Audit and Advisory Services Center.
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